Personal Data Privacy and the Internet - A Guide for Data Users

Identity of the organisation

It is possible that an organisation may collect personal data via the Internet without publishing contact information other than its web address. Very often, the web address does not disclose the actual identity of the organisation. This practice may be inconsistent with the requirement of DPP1 which provides that personal data shall be collected by means which are fair in the circumstances of the case, i.e. it may be unfair for a data user to collect personal data without revealing its true identity.

=>Avoid the Web facade. Provide web pages that make available information "About the Organisation". Include the name, physical location and contact telephone/fax numbers of the organisation in addition to the web address or e-mail address. This would be a reliable channel through which a web user could contact the organisation.

The main purpose of this Guide is to assist data users (referred to as "organisations" in this Guide) in complying with some of the more common applicable requirements of the Ordinance when they are collecting, displaying or transmitting personal data over the Internet.

(The six data protection principles in the Ordinance are set out at the end of this Guide together with a glossary of the terms used in this Guide)